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BLM officials stated that operating contrary to implemented legislation by limiting sales and not destroying horses has contributed to an unmanageable number of horses.

From the Office of Inspector General, U.S. Department of Interior:

Report Date:

Friday, October 23, 2015

The Office of Inspector General completed an investigation into Tom Davis, a Colorado rancher and livestock hauler, after receiving allegations that Davis purchased approximately 1,700 horses from the Bureau of Land Management’s (BLM) Wild Horse and Burro Program (WH&B) between 2008 and 2012 and wrongfully sent the horses to slaughter.

BLM established WH&B to protect, manage, and control the wild horse population. Since establishment of the program, Congress passed several laws that provided for protection and management of these animals, including adoption and sales authority. In 2005, BLM implemented a policy that placed limitations on the amount of horses sold and required buyers to provide good homes and humane care to prevent the horses from being sent to slaughter.

During our investigation, Davis admitted that most of the horses he purchased from BLM went to slaughter, but he denied that he transported the horses directly to slaughter. He explained that prior to purchasing horses from WH&B, he made arrangements with buyers—whose names he would not disclose—who transported the horses to Mexico. Davis said WH&B employees asked him several times if he was selling the horses to slaughter. He reassured WH&B that he was not selling them to slaughter and reported on his applications that the horses were going to good homes. Davis also admitted that he knew he was not supposed to sell the horses to anyone that would take them to a slaughterhouse.

In addition, we found that BLM implemented and followed policy that contradicted legislation, by not destroying horses to maintain an ecological balance, and the 2004 Burns Amendment, by placing limitations on horse sales. BLM officials stated that operating contrary to implemented legislation by limiting sales and not destroying horses has contributed to an unmanageable number of horses.

We referred this investigation to the U.S. Attorney’s Office for the District of Colorado as well as the State of Colorado Conejos County District Attorney’s Office, which declined civil and criminal prosecution.

America’s wild horses from the Palomino Valley and Fallon holding facilities in Nevada did not get their fair share of exposure for adoption on the internet because they were listed late. Therefore they should not be given a strike because they were not picked. It’s not their fault.

We ask that the Bureau of Land Management (BoLM) do the right thing and wipe off the strike these wild horses received for not being adopted in the last round online.

America’s mustangs in the adoption program should go to good homes or sanctuaries if they cannot be returned to the land where they belong.

Contact your elected officials and ask them to intervene to stop these beautiful wild horses from the unfair 3-Strikes practice that puts them at risk. After 3-Strikes, federally protected American wild horses lose their protections and legally can be sold for $25. People sell 3-Strikes wild horses to “horse-traders” who sell to kill buyers selling to slaughter.

Contact us if you need help adopting wild horses and navigating the BoLM’s red tape, problem solving when problems arise, etc. Email us directly at Contact@ProtectMustangs.org Let’s get the wild horses to safety! Together we can turn this around.

Protect Mustangs is an organization who protects and preserves native and wild horses.

Government: People who want the formerly wild animals are supposed to wait a year to get title before they can be sold. But enforcement is lax and many end up slaughtered.

ALBUQUERQUE, N.M. — A federal program to protect wild horses and burros has lost track of more than 32,000 animals placed in adoption, allowing people to neglect, abuse and even slaughter some of them for profit.

In addition, officials of the U.S. Bureau of Land Management may have falsified records to cover up the problem and ignored warnings that thousands of adopters have not been checked and have not received titles to their animals, according to documents obtained by the Associated Press.

“Records are systematically falsified and no one wants to know about it,” said Reed Smith, a former BLM administrator who retired from the New Mexico office in 1995.

In 1971, Congress enacted a law to protect wild horses and burros and place excess animals for adoption. In 1978, to better prevent their slaughter or sale, it created a system of legal titles: The adopter would keep each animal for one year, comply with a health check, then get title.

Until the title is issued, the animal would remain government property.

Using the BLM’s computerized records maintained in Denver and obtained through the Freedom of Information Act, the AP found that 32,774 of all adopted animals–or 20%–remain untitled. Legally, those horses and burros are still federal property.

The adopted horses were given to more than 18,000 different people.

Last month, the AP reported that the $16-million-a-year program has allowed thousands of titled wild horses and burros to be slaughtered. The investigation found that BLM employees are among those profiting from the slaughter.

In response to the first report, Wild Horse and Burro Program chief Thomas Pogacnik wrote: “Once title is issued, the animal is private property.”

Under the 1971 law, Interior Secretary Bruce Babbitt is mandated by Congress to protect wild horses and burros on public lands. Babbitt refused to comment for this story.

BLM officials say they rely on spot checks to trace horses that remain untitled. But Larry Woodard, the former state director of New Mexico’s BLM office, called spot checks inadequate.

“One out of every five animals adopted by the bureau never being titled would indicate that the titling aspect of the adoption program has not been a subject of intense concern,” Woodard wrote in a 1993 memo.

A U.S. Justice Department memo from April 1996 indicated that the BLM is not carefully screening adopters because the agency does not want to know what happens to the animals.

“The Adopt-a-Horse program is seriously flawed. . . . BLM has an unstated policy of not looking too closely at proposed adoptions,” wrote Charles Brooks, a Justice Department attorney who had been assisting the U.S. attorney’s office in Texas with an investigation of the program. “The agency’s approach to this was its version of ‘Don’t ask, don’t tell.’ ”

A March 27, 1995, internal memo from that investigation quotes BLM law enforcement agent John Brenna as saying that Lili Thomas, a BLM official, made “a tacit admission of backdating documents used in the Wild Horse and Burro Program.”

“Her additional comments were that she did not know if this was illegal or not,” Brenna wrote.

Thomas did not immediately respond to messages requesting comment. Brenna refused to comment.

In the 25 years since the law’s passage, the BLM has gathered 165,635 animals in 10 Western states deemed “excess” and given most of them to adopters for $125 each. About 40,000 horses and burros remain in the wild.

Thomas Sharp, a 43-year-old wheat and alfalfa farmer, sits in a West Texas penitentiary, the only person in the country in federal prison for selling untitled horses.

He says he couldn’t afford to feed the animals and didn’t bother to send in a form requesting title. “They got me on a signature, but they got me, that’s for sure,” he said.

Assistant U.S. Atty. Hank Hockeimer of Oklahoma said he hoped Sharp’s four-month sentence would set an example.

“Our purpose for prosecuting this case was to send a message that under this program you can’t ostensibly adopt these horses and then sell them before you have title,” he said.

The AP contacted 20 adopters of untitled horses last week, but only two still had their animals. One said his horse died, another gave his away and the rest said they had sold their untitled horses, mostly at livestock auctions.

Wild horses sold at auction almost all eventually end up slaughtered, according to the operators of North American horse slaughterhouses.

George Varner Sr., who spent 20 years as a “killer buyer” for slaughterhouses, said one or two wild mustangs show up at auction barns each month in central Mississippi alone.

He said the only people willing to bid on the horses are the slaughterhouse buyers. “These horses aren’t good for anything else,” he said.

The AP’s Fred Bayles, Chris Sullivan and Drew Sullivan contributed to this report.

Protect Mustangs is an organization who protects and preserves native and wild horses.

While pretending to rely on the assumption that herds grow 20% a year, the Bureau of Land Management (BLM) posts numbers up to 8 times higher than that to justify roundups, which are pre-scheduled on a rotation-basis, seeming to target particular herds. For instance, the Agency recently claimed that the famous Kiger herd in Oregon grew from 21 horses to 156 horses in just four years — an increase of 643%, which equates to a yearly average increase of 160%, which is 8 times higher than the 20% BLM supposedly uses. [1] Such growth is biologically impossible. Kiger is not an isolated example, although it is the worst found so far. Here are some other phony figures on population-growth recently claimed by BLM to make it appear that gathers were necessary:

Green Mountain (WY)
281% increase in four years, averaging 70.3% per year

Stewart Creek (WY)
311% increase in four years, averaging 77.8% per year
But herd-growth is unlikely to reach even 20 percent a year. It is important to understand that the birth-rate is not the same as–and should not be equated to–the population growth-rate. Here’s why: Horses die. An independent study reviewed BLM roundup-records for a representative sample of four herd management areas composed of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth-rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival-rate is just 10 percent. Further, adult wild horses also perish. They succumb to illness, injury, and predation. Their death-rate must be taken into consideration as well. But BLM ignores mortality–foal and adult–in its population-estimates. Given the 50% foal mortality-rate, and the 5% or higher average annual death-rate of adult wild horses, herd-growth could not increase 20% a year, and a herd-population could not double in 4 years–refuting yet another BLM myth.

Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates–that is how BLM creates the false impression of a population-explosion. But “cooking the books” is not the only way BLM falsifies the population-picture. Another ruse BLM employs is restricting maximum herd-size below minimum-viable population (MVP) size. Then, whenever a herd is made to appear–via fictitious figures–to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70 percent of the herds are “managed” below MVP.

BLM also fails to consider another factor limiting herd-growth–stochastic events–which are random catastrophes such as wildfires or contagious diseases that suddenly wipe out mass-numbers of herd-members. Stochastic events can result in no-growth or even negative growth.

Now BLM is distributing grant-money to universities and researchers to study more ways of dealing with the phantom overpopulation. All manner of sicko experiments are being carried out on the wild horses, such as treating them with endocrine disruptors and sterilizing them surgically. Why? Because BLM is a corrupt agency. It invented this counterfeit crisis to create a sense of urgency, which will pressure Congress to give the Agency extra money to “solve” a non-existent problem.

Contact your elected officials to make them aware of BLM’s fraudulent population claims to get funding for wild horse roundups and warehousing at great taxpayer expense: http://www.contactingthecongress.org

Visit www.ProtectMustangs.org for more information and click on the donate button help fight the injustice! You can make a difference.

Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.

(Photo by BLM. Roundup paid for with your tax dollars.)Addendum:

[1] Using simple division to calculate the average increase is how most people would “do the math”–dividing the percentage increase (643%) by the number of years (4). Expressing the average that way is readily understandable. However, another way of calculating it is what is called the “compound annual growth rate” (CAGR). Per that method, herd-growth can be likened to compound interest that you earn on a savings account; except of course that horses do die, which complicates the computations. But for now, let’s assume that horses never die, because that’s the assumption that BLM makes.

Using the free, online CAGR tool linked below, you would enter Kiger’s beginning population–21–and its alleged ending population–156–and the number of years that had passed–4. Then press the “Calculate CAGR” button, and the tool will compute the compound annual growth rate. For the Kiger herd, the CAGR is 65%, which is “only” 3.25 times higher–instead of 8 times higher–than 20%.

At the link below, you will find a discussion posted by the University of Oregon, providing a comparison between the simple average and the compound annual growth-rate methodologies for calculating annual percentage population-growth.

As will be readily apparent, the simple average approach is “straight-line” and … simple. Forgive yet another pun, but the average person can easily understand it and “do the math.”

The compound annual method, on the other hand, is extraordinarily complicated to compute, which is why the online tool is almost a necessity.

What is important is that both are legitimate ways of describing the data.

It should be kept in mind that population-growth estimates must consider births and deaths, not just births. That’s one reason why the Gregg et al. study was so important — it established, per BLM’s own documentation, a slightly-less than 20-percent birth-rate and a 50-percent foal mortality-rate. So, a wild-horse herd growth-rate of, for example, 65%, would have to mean a birth-rate that was much higher than 65% to offset foal deaths (50%) and adult deaths (5%).

Baby Spitfire was born out of a miracle rescue. Her papa was brutally slaughtered shortly after 41 wild horses in Wyoming were rounded up in the March 2014 BLM stealth roundup and were quickly sold off by the WY Livestock Board at auction to the most prominent slaughterhouse in North America–who slaughters wild and domestic horses for human consumption abroad.

Mark Boone Junior (Bobby Elvis on Sons of Anarchy) and Anne Novak found the only mustangs left alive at the slaughterhouse yard–14 young and terrified wild horses. Thanks to everyone’s prayers and good vibes they resuced the WY14 back from the slaughterhouse before they were live-shipped and turned into sashimi over in Asia. Read about the rescue here: http://protectmustangs.org/?p=6775 .

Little did they know that a member of the WY14 was carrying a little treasure through all the turmoil and terror.

Please help with a tax-deductible donation for the hay drive to get a semi-load of hay for the WY14-15. They are all growing and need more hay!

Welcome Spitfire! You will carry on the bloodline that those dumb bureaucrats at the BLM thought should be disposed of. SHAME on them.

I understand that your office has scheduled another roundup-and-removal operation pertaining to wild horses that allegedly have wandered outside the …

Sulphur HMA

… and that are, reportedly, posing safety-concerns along Highway 21.

I am submitting substantive comments and new information that BLM-Cedar City should consider. I urge you to cancel the gather, correct the population-estimate errors, investigate the validity of the accusations, complete an environmental assessment, fence Highway 21, and take other preventive measures.
REASONS CITED BY BLM FOR SPECIAL ROUNDUP
Overpopulation, Forage Limitations

BLM’s News Release identifies the issue as being wild horses “causing public health and safety concerns along Highway 21.” BLM lists overpopulation and forage limitations as the causes for the horses having allegedly migrated to the outer edge of the Sulphur HMA, near said highway.

The Proposed Action

BLM-Cedar City plans to round up and remove a total of 100 wild horses out of a population that BLM estimates at “approximately 830” (versus 250, the high-bound of the AML). The gather, scheduled to begin only days after issuance of the News Release and in the absence of an environmental assessment, would be accomplished via helicopter-drive. The roundup would supposedly target members of the Sulphur herd that are “encroaching on Highway 21.” But, given wild horses’ propensity to roam extensively, it is unclear how the true perpetrators would be identified.

The Issues

There are several important questions concerning the planned gather that BLM has not addressed.

What is the right solution for preventing vehicle-wildlife collisions?
What is the accurate estimate of Sulphur HMA’s wild-horse population?
Is there really an overpopulation? Has AML been exceeded?
Who has reported wild horses “along Highway 21”? Rogue ranchers?
How likely is it that 100 wild horses are encroaching on the highway?
Is the “public safety” excuse an end-run to skip an environmental assessment?
Was the snap-decision to hold a gather a strategem to avoid scrutiny of the data?
Are the pretty stories about adoptions and retirements-to-pasture just fables?

A review of BLM’s data — its assumptions, claims, population-estimates, gather-data, and PZP-inoculations — for the Sulphur herd disclosed

Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes, and
Ignorance of new studies that found herd-growth averages 10 percent — not 20.

FENCE OFF HIGHWAY 21
Outsiders — Dealing with Roving Equids

Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered outside the boundaries of an HMA — “outsiders” — just creates a vacuum for “insider” horses to fill. Thus, removing “outsiders” is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in recolonization by other mustangs. Absent barriers, the process begins almost immediately, as horses come upon an area and see that it is attractive … and vacant. This is exactly what has happened! BLM removed 30 wild horses “from the same area” just months ago. Yet, here we go again. Thus, removal is not the solution.

Recommendations: When horses stray, BLM-Cedar City should round them back in! Encourage the outsiders to return to their proper place, then address those factors that caused the animals to leave home.

Does the HMA have perimeter fences?
Do the fences need repair?
Do the gates need to be checked frequently and closed?
Would palatable plantings draw the wild horses back inside the HMA?
Have mineral licks been placed well-inside the HMA?
Have guzzlers been installed to provide water sources within the boundaries?

And, most importantly, …

Why hasn’t Highway 21 been fenced off near the HMA?

BLM-Cedar City should specify preventive measures in this regard as its management approach. Return outsiders to the HMA. Fence the HMA’s perimeters.

Fence Off Highway 21 near Sulphur HMA, Install Wildlife-Underpasses

Highways that cross near wildlife-habitat need to be fenced off. Installing safety-fences is certainly the indicated, cost-effective, and long-term solution. By preventing horses — as well as other creatures — from crossing directly over a highway, fences keep animals from endangering themselves and motorists. Underpasses allow wildlife to migrate freely, but safely.

I urge BLM-Cedar City to install a system of fences and underpasses along Highway 21, where the road approaches the Sulphur HMA. Highway 21 has been described as “remote,” suggesting that traffic on it tends to be sparse, which should minimize inconvenience during installation of these protective features. Funding should be sought from BLM-National, BLM-Utah, your own Field-Office budget, and other state, local, and private sources.

Wildlife Underpasses — Historical Perspective

Utah can rightfully claim that it was the first state to install a wildlife-crossing in North America. In 1971, such an overpass was constructed south of Beaver.

Fast-forward to 2013, when a partnership of governmental agencies and private groups in Utah installed a system of fencing and underpasses along a 12-mile stretch of US Highway 89. The purpose of the $2.6 million-project was to protect Paunsaugunt mule-deer-herd during the animals’ seasonal migrations. The subject deer are considered trophy-caliber among sport-hunters, many of whom spend thousands of dollars to shoot one. But, prior to the installation of the fences and underpasses, an average of 100 mule-deer a year were being killed by collisions with automobiles.

What caught my attention was that the project was largely funded by … BLM — even though only 23 percent of the Paunsaugunt Plateau is on BLM-administered land.

The State’s management-objective for the mule-deer herd in the Paunsaugunt is a population of 5,200 to 6,500 wintering deer. In addition, predators — specifically, cougars — are “managed” … by hunting them … to “benefit” the deer — or is it to benefit the hunters wanting to kill the deer? Thus, the natural ecological balance is disturbed for the sport of humans.

Interestingly, the most recent data I could locate on Utah’s mule-deer population indicated that, post-harvest of 25,000-plus bucks in 2013, there were 332,900. Unlike neighboring states, Utah has a thriving mule-deer population. The International Union for Conservation of Nature (IUCN) categorizes the mule deer’s conservation-status as a species of “least concern” (LC). Mule deer have even been introduced to … Kauai, Hawaii. Yet, BLM was willing to spend millions to keep 100 of them safe. Surely, BLM will find a way to protect our precious-few-remaining wild horses. The answer is: Fence Highway 21 near the Sulphur HMA!

Not perfectly, but pretty well, according to the article linked below. Deer-deaths are down. Reportedly, it takes about three years for wildlife to become accustomed to the new funnel-structures, so results should continue to improve. One snag was cited: Opportunist-hunters set up camp near the underpasses, and shot deer passing through the funnel. Consequently, other deer, sensing danger, avoided the structures.

You already have the template from the Highway 89 project. Lessons have been learned — what worked, what didn’t, and how the system could be improved. Thus, implementation of a corresponding project for Highway 21 should go smoothly. Fence it, and they will cross through the underpasses.
FLAWED POPULATION ESTIMATES
Unlikely Birth-Rate

According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.

HMA and HA Statistics reports for the Sulphur herd from 2008-2014,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in BLM’s News-Release,

discrepancies are evident.

Sulphur HMA — Utah — Herd Population Changes — 2008 to 2015

The following chart merges the yearly population-estimates with the gather and contraceptive data to reveal how the numbers were calculated and where errors were made. The beginning-of-the-year figure for 2015 — the pre-gather estimate — is per the BLM’s News Release.

The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.

Societal Impact of Inflated Population-Data

The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public in an uproar over an “overpopulation” that BLM’s faulty figures portrayed.

Recommendations: BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must correct the record and make genuine efforts to stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.

Mistakes Cost Wild Horses Their Freedom

The planned removals appear to have been hurriedly scheduled to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by faulty figures.

Not the First Time Population-Estimates Were Found to Be Flawed

In May 2014, I submitted comments regarding the environmental assessment for Bible Spring Complex, which is also under BLM-Cedar City’s jurisdiction. For the three HMAs and the one HA that compose the Complex, major discrepancies were disclosed — one-year growth-rate-estimates of …

125 %
131 %
153 %
157 %
249 %

Thus, the errors uncovered with regard to BLM’s population-estimates for the Sulphur HMA are not isolated instances. Together with those revealed for the Bible Spring Complex, these disparities point to a systemic problem.

Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it inadvertently portrayed an incorrect picture — an exaggerated picture — of the herd’s population.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER BLM METHODOLOGY
Projections per a Twenty-Percent Foal-Survival Rate

Let’s see how the population numbers should look if we used BLM’s assumption of a 20-percent foaling-rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).

Why 2014’s foals should be excluded: When determining animal-unit-month (AUM) use, BLM counts a cow and her calf as one unit. Likewise, a wild mare and her foal should also count as one unit. But in recent years, BLM has been counting foals as separate units. BLM has even been caught estimating wild-horse populations — and thus, AUM-use — to include newborn and even unborn foals. The correct and equitable approach is not to count foals, and certainly not to count fetuses.

Note about birthdays: Some might argue that all horses celebrate their collective birthday on January 1. But that practice is merely a convention of breed-registries, causing their members to employ artificial means to force mares to ovulate out-of-season in order to avoid their offspring being at a physical-maturity disadvantage vis-à-vis competitors. True age is biological age, and wild foals will not be true yearlings for several more months, until spring.

Factoring in PZP’s Impact: Herd size was affected by removals and by PZP. Removals, we know. As for PZP, the picture becomes murky.

Dr. Jay Kirkpatrick, the developer of PZP, claims that PZP treatment of wild horses is greater than 95-percent effective.

A study by Turner et al. (2007), which was cited in the National Research Council’s report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, found that PZP-22 remains 85-percent effective after 22 months. Moreover, PZP is known to exert significant contraceptive effect in the third year and beyond.

However, there are too mainly unknowns for me to factor in PZP’s effect on the Sulphur herd’s growth. So, to proceed conservatively, the estimates below ignore PZP initially and, thus, overstate the population to an unknown extent in that regard. An adjustment will be applied at the end to offset this.

Deaths on the range: Finally, it is assumed — wrongly, but for sake of initial estimates — that no horses died in the past seven years. The estimates ignore fatalities and, thus, further overstate the population. An adjustment encompassing PZP and fatalities will be applied to arrive at a working-estimate.

Bottom line: Every benefit-of-the-doubt has been given.

Sulphur HMA — 20% Growth — Reflecting removals, but not PZP or deaths

2008 — 190 — BLM’s population-estimate post-gather November 2008

Year Herd-size
January 1

2009 — 190 — Foal-crop: 38. Those foals would have been born in spring.

It is clear that, using BLM’s own data and the “20-percent-per-year” rule, BLM’s population-estimate, with or without the 2014 foal-crop, was about double that of a properly-calculated estimate.

Conclusion: If we were to accept BLM’s thesis that the herds grow 20 percent every year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 350. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.

Yes, the estimate exceeds the assigned AML. However, in this case, being “over AML” is not meaningful because the AML and the working-estimate reflect a herd-level that is …

Below minimum-viable population.

No wild horses should be removed. Complete an environmental assessment as required, and fence off Highway 21.

Planned Roundup Would Have a Devastating Impact on the Sulphur Herd

Per the working-estimate of 350, if BLM were to remove 100 horses from the Sulphur herd, it would be a sudden, drastic reduction — nearly 30 percent of the herd. In addition, the type of roundup — targeting horses near Highway 21 — would ignore bloodlines and essentially be a “gate-cut.” Thus, the herd’s genetic viability would be further impaired.

The International Society for the Protection of Mustangs and Burros (ISPMB) has just completed a 14-year study of wild-horse population-growth. The ISPMB herds have been managed per the “hands-off” minimum-feasible level specified in the Wild and Free-Roaming Horses and Burros Act.

Results: The study-herds grew from 5-to-10 percent a year. During the study, there were …

No removals
No predators
No PZP

Here is the link to the letter sent in this regard from ISPMB to the Department of the Interior and Bureau of Land Management.

The researchers found an effective foal-to-yearling survival-rate of just 10 percent. No matter the birth-rate, what counts is survival. The same pattern likely holds true for the Sulphur herd. Per this study, BLM-Cedar City’s assumed growth-rates for the Sulphur herd are deemed not credible.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER NEW RESEARCH-FINDINGS
Projections per a Ten-Percent Growth-and-Survival Rate

Let’s see how the population numbers would look if we correctly assumed a ten percent foaling or survival rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).

It is clear that, using BLM’s own data and the “10-percent-per-year” research-finding rule, BLM’s population-estimate, with or without the 2014 foal-crop, was more than triple the properly-calculated estimate.

Conclusion: If we were to accept the new research-findings that herds grow 10 percent a year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 210. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.

However, please note that the working-estimate derived per the independent research’s findings of 10-percent growth reflects a population that is …

Below AML and
Below minimum-viable population.

It is clear that BLM should be estimating the wild-horse population according to the latest scientific knowledge. Therefore, no wild horses should be removed. Instead, complete an environmenal assessment and fence off Highway 21.

Could There Really Be 100 Wild Horses Wandering onto the Highway?

Out of a herd best-estimated at 210, it seems implausible that 100 horses — virtually half the population — would have left the 265,711 acres of the HMA and begun hanging out near Highway 21. Indeed, the public safety “concerns” appear phony — like they might well have been concocted by rogue ranchers and seditious county commissioners. The safety-complaint seems more of a ruse to push BLM into conducting a major removal-action that will inure to the benefit of permit-holders. Those parties are agitating to have the State of Utah take over Federal lands and the management of our wild horses. Getting rid of the horses is the ranchers’ goal.

Unfortunately, BLM’s previous erroneous population-figures made it seem that the ranchers were right about an overpopulation of wild horses, and that by removing just 100 of them, BLM would hardly be making a dent. Thus, it is imperative that BLM set the record straight.

Happy Tone, Ugly Reality

BLM’s News Release is deceptively friendly in tone — from naming a meet-up point from which BLM invites prospective observers to start the “escorted tours” to the standard feel-good language about captured horses finding “new homes with families” and pleasant-pastures-for-life for those horses not adopted. Behind the facade, the reality is another story.

Claim of exigency regarding public safety;
Claim that is unverified and reeks of maneuvering by local ranchers.
Pretense that 100 horses are “encroaching on Highway 21”;
Removing horses rather than installing fences along the Highway.
Pretense that population-estimates are reliable numbers;
Finding of huge discrepancies in those estimates.
Pretense that an environmental assessment isn’t necessary;
Reality that an EA is required.
Pretense that only 12 percent of the herd would be removed;
Reality that 50 percent of the herd would be unlawfully taken.
Feel-good stories of adoptions and wild horses peacefully living out their lives at pasture
Reality that many of them would be — as they have been — sold to slaughter
ADOPTION … OR HIGHWAY TO HELL?
Sale to Slaughter for Sulphur HMA Captives

BLM’s News Release is disingenuous where it claims that wild horses “removed from near Highway 21 will be made available for adoption through the BLM Wild Horse and Burro Adoption Program.” The News Release is also dishonest where it promises that wild horses “not adopted will be cared for in long-term pastures, where they retain their ‘wild’ status and protection under the 1971 Wild Free-Roaming Horse and Burros Act.” If only those fairy tales were true. Unfortunately, the opposite is the case. Said adoption program is conducted to bring “three strikes and you’re out” to as many horses as quickly as possible, making them eligible to be sold rather than adopted. The long-term pastures program is shrouded in secrecy. The public has no access to check on the horses’ welfare. Past scandals have revealed BLM staff involved in selling wild horses to kill-buyers.

A review of BLM records of recent “adoptions” of wild horses that were removed from the Sulphur HMA just six months ago as part of the earlier “near Highway 21” removal disclosed instances of the Adoption Program auctioning off horses online for just $25, with free delivery to sites known to be frequented by kill-buyers.

Were the mares at issue among those that the New Release reported to “have found new homes with families”? Or did BLM remove wild horses from “near Highway 21” only to send them down a “highway to Hell”?
SULPHUR HERD’S AML WAS SET AT A GENETICALLY NON-VIABLE LEVEL
AMLs Should Provide for Better Than MVP, but Must Provide for At Least MVP

BLM is required by law to manage the wild horses in self-sustaining herds. To be self-sustaining, a herd must be genetically viable. To achieve viability, sufficient population is necessary.

A scientifically-valid AML needs to comply with the recommendations of the International Union for Conservation of Nature (IUCN) regarding adequate herd-size for equids. Increasing the AML per the IUCN guidelines also comports with the results of a recent meta-analysis regarding minimum viable population (MVP). Here are the links to the IUCN discussion on equid herd-size and to the MVP meta-analysis report:

BLM needs to increase the low-bound of the Sulphur AML to at least 2,500 and the high-bound to at least 5,000. BLM does have the authority to modify AMLs, and should correct Sulphur herd’s through amendments to the Resource Management Plan (RMP) and Herd Management Area Plan (HMAP). These actions should be taken right away. The corrected AML will result in a stocking-rate of one horse per 53 to 106 acres, which compares favorably with the one cow or calf per 38 acres that BLM allows on federal lands, as shown in the analyses that follow.

But can the Sulphur HMA, composed of 265,711 acres sustain up to 2,500 mustangs at 106 acres per horse? What about 5,000 mustangs at 53 acres per horse?

BLM’s approach to determining appropriate levels of livestock-grazing suggests that the answer to both questions is “Yes”.

Below are the National statistics for authorized commercial livestock-grazing on BLM lands per animal-unit months (AUMs). Note the stocking rate: One cow or calf per 38 acres.

157,000,000 acres of public lands on which BLM allows cattle

1,033,333 cow+calf pairs that BLM permits to graze = AUMs annualized

2,066,666 cow+calf pairs per typical 6-month permit = annual AUMs x 2

4,133,332 cows and calves = pairs x 2

38 acres per cow or calf

BLM may argue that actual livestock use is lower than authorized or permitted use. But because actual use is whatever the permit-holders report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not (see Bundy, Cliven), the actual-use number is unverified and likely grossly under-reported.

Actual Grazing Use Report — Form 4130-5

As alluded to above, permittees are required to submit an annual report of how many livestock they put out on their respective allotments and for how long. Form 4130-5 “Annual Grazing Use Report” is used for this purpose. It’s a one-page document that BLM estimates to take 15 minutes to complete “… including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form.”

Form 4130-5 is the basis on which BLM bills the permit-holders. It is also the basis for the claim of reduced-use. Thus, grazing-use is a self-reporting, self-certifying system that is rarely verified. The ease with which permittees could game the system is obvious. Consequently, the veracity of the reports is suspect.

Bundy-Supporting Permittee Grazed His Livestock beyond Authorized Use

In neighboring Nevada, permit-holder Kevin Borba, whose allotment includes land inside the Fish Creek HMA, engaged in unauthorized livestock-grazing “consistently for six months” outside the permitted use. He had his cattle out there year-round. He owes $29,410.62 in fees and fines for willful trespass, but has subsequently sued BLM over the loss of his “rights” and to stop BLM from returning any wild horses to the range following the recent gather.

Such abuses by permittees are likely widespread. Cliven Bundy and Kevin Borba are not alone in this regard. Utah has its share of rogue-ranchers too, as recent events have demonstrated.

What If There Is Not Enough Forage to Support 5,000 Horses?

Nature has its feedback mechanisms that function to right-size a herd to fit the land’s carrying capacity. Biologist Robert Bauer points out that

… density dependent inhibition plays an important role also. In this scenario, what that means is that the numbers or density of wild equine, versus competing ruminants, such as the pronghorn, each will fluctuate in response to the other based upon the carrying capacity of the land, yet always in perfect balance. In essence, the pronghorn need the presence of wild horses and burros, just as much as the wild horses need the pronghorn. Each population will have the effect of keeping the numbers of another competing population at levels that are ideal for the carrying capacity of the land.

Careless and excessive removals of wild horses can nullify preservation-efforts. Thus, the very characteristics for which this herd is known could be lost by ignorant management. BLM-Cedar City is duty-bound to conserve the Sulphur herd and manage it for a self-sustaining, genetically-viable population.

Recommendations: Perform a complete genetic study of the herd. Per test-results on DNA samples analyzed by the Equine Genetics Lab and per guidance from Dr. Gus Cothran, BLM must then develop best management practices to restore and maintain gene-pool diversity via robust population-levels. An AML is valid only if it provides for a optimal population — one that can easily self-sustain its genetic viability and bounce back from random catastrophic events. It is not scientifically valid to conduct removals blindly — without regard to the herd’s genetics. Submitting DNA samples after-the-fact has it backwards.

There should be no removals or contraceptions without knowing and managing per the genetic data for each herd-member.

Drastic Limitation of Herd-Size Leads to a Non-Viable Gene Pool

I would urge the BLM-Cedar City to study the topic of “genetic drift.” An excellent resource is linked below. Please note that stochastic events — random, chance happenings — can eliminate important survival-supporting, adaptive genes from a population. BLM’s currently-inadequate AML, enforced through sudden, draconian removals and mass contraceptive vaccinations, could randomly wipe out certain traits that are valuable and well-worth conserving.

Please study the danger of creating a “population bottleneck,” which is especially risky when a population is small, as is the case with the mustang-herd in question. Please also review the topic of the “founder effect” — which occurs when a new colony is started by a few members of the original population. It too would apply to previous removals. Refreshing your understanding of these evolutionary impacts will surely make it clear that the proposed intensification of PZP treatment is contraindicated. Here is that link:

Removal of Young Horses that May Be Their Sire or Dam’s Only Offspring

Captured horses would likely consist predominantly of mares and their foals, along with band-stallions. Bachelor-stallions escape more easily, resulting in a gender-ratio imbalance post-gather. Too few mares and too many studs is bad for the gene-pool. BLM-Cedar City must be careful in this regard. Because the Sulphur herd’s current population is below MVP, and because mares have been contracepted, certain bloodlines could be extinguished by mass-removals.
A HELICOPTER-ROUNDUP IS ILL-ADVISED FOR SEVERAL REASONS
Helicopters Are Not Safe

BLM-Cedar City has been informed, in previous comments, that helicopters crash a lot. For that reason, helicopter-use should be restricted to functions in service of a higher good, such as saving lives or fighting fires.

Peculiar Way of Addressing Safety Concerns

Please note the irony of using a helicopter-stampede — a dangerous method — to deal with an alleged public-safety concern. Rather than increasing safety, this approach decreases it.

Helicopter-Drive — an Inhumane Roundup Method

Using helicopters to round up wild horses is inhumane. There is no way to make it humane. Helicopter-roundups are examples of worst management practices. It is a national scandal that they still continue, bringing disgrace to the Agency and reflecting poorly on the Administration.

Abusive Behavior by Helicopter Pilots during Gathers

As has been documented on video, helicopter-pilots conducting roundups become frustrated by the wild horses’ lack of cooperation. Impatient to get the horses moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. Worse yet, much of the abuse goes undetected because the roundup-pilot generally flies solo.

There has also been documentation of contractor-wranglers whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.

No Horse Left Behind

The helicopter contractors are incentivized to leave no horse ungathered. In addition to the flat-fee-for-service, they earn a per-horse-fee. Thus, they have reason to go after every last horse in order to “make their numbers.” Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment. We also observed how the attending USDA veterinarian and the BLM officials present did nothing to stop the abuse.

An Angry Contractor May Be Headed Your Way

In case BLM-Cedar City were planning to employ the same helicopter-contractor who just worked the Fish Creek gather in Nevada, here is information you need to know.

Because that roundup was called off about 75 horses short of the planned number, the contractor was not happy. In fact, he tried to confront one of the humane-observers to make his displeasure known. She wisely refused to be provoked and just walked away.

Because the contractor’s profit-pump is primed, he could likely be more aggressive than usual. He could take out his frustrations on the horses.

Some Observers May Be Pumped-Up Too

Roundup-observers are bound to include anti-wild-horse parties — local ranchers, local elected officials. They are likely to be eager to bring a lawsuit against BLM on any pretext in sympathy with the Bundy-supporting, trespass-permittee in Nevada who, along with Eureka County Commissioners, just filed an IBLA appeal with regard to the Fish Creek gather.

The political weather is unstable. That is another good reason to call off the roundup.

Easy for Helicopter-Pilot to “Poach” Wild Horses from Neighboring HMAs

A glance at the map of the Sulphur HMA shows that Highway 21 approaches its boundary at one point before veering off again. The map also shows that Highway 21 passes by Blawn Wash, which is not-that-far east of the Sulphur HMA. Blawn Wash is associated with the Bible Spring Complex. However, having been downgraded to an HA, Blawn Wash is officially “off limits” to wild horses.

How easy it would be for a disgruntled and therefore highly-motivated helicopter-pilot to “poach” wild horses from the Bible Spring Complex by driving them into Blawn Wash. What would stop him from capturing wild horses that never set hoof near Highway 21? BLM needs to ask itself: Are we honestly trying to catch the Highway 21 trespassers, or are we allowing permittees to bully us into removing any 100 wild horses that the helicopter can find? The horses thus-captured might not even include the few that are — allegedly — “encroaching” on the Highway.

4. Fence off Highway 21. Install wildlife-underpasses as needed. Apply the funds you would have used for this gather to begin construction of fences and underpasses.

5. Bring ’em back home. In the meantime, if a few wild horses really are straying onto Highway 21 — and the claim seems suspiciously-like a self-serving story that ranchers would invent — then BLM staff on horseback should be out on the scene “shooing” the mustangs back into the HMA. How else will the horses learn where they can and cannot roam? In short order, they will get the message.

6. Make it so they want to stay home. BLM should install multiple guzzlers deep within the HMA so that the wild horses will have water-sources available. That will reduce their dependency on stock-tanks operated by permit-holders. BLM should also entice the horses to stay home by placing treats such as mineral licks well-inside the HMA. BLM must remediate conditions that prompted the wild horses to wander. However, if the horses are following a seasonal migration route, then a wildlife corridor for them must be established. Regardless of these good measures, it is still essential to fence off Highway 21.

7. Amend the RMP and HMAP now to provide for a genetically-viable herd. The current AML and the actual wild-horse population of the Sulphur HMA are below mininum-viable population (MVP).

8. Increase the low-bound of the AML to 2,500 and the high-bound to 5,000.

Please help network these wild horses to a good home. They received a STRIKE against them from the last Internet Adoption because they were passed over.

MARY in foal #08022753

Sex: Mare Age: 7 Years Height (in hands): 14.1

Necktag #: 2753 Date Captured: 10/14/14

Color: Bay Captured: Palomino Buttes (OR)

Notes:
Tag#-2753. This is a 7 year-old bay mare gathered from the Palomino Buttes HMA in OR in October 2014. Freezemark: 08022753

There is a likely possibility that this mare is currently carrying a foal. By the time the internet adoption closes and shipping arrangements are made, this horse will be too far along in her pregnancy to travel healthily via livestock truck hauling. Therefore…this horse MUST BE PICKED UP directly from Oregon’s Wild Horse Corral Facility in Hines, OR.

There were no bids placed on MARY during the last Internet Adoption so she received another STRIKE.

Mary needs someone to care for her and her foal. If she gets 3 STRIKES the BLM can legally sell her to slaughter according to the Burns Amendment. Please contact us if you run into BLM red tape. Our email is Contact@ProtectMustangs.org

SAM is only 2 years old and he received another STRIKE

Sex: Gelding Age: 2 Years Height (in hands): 14.1

Necktag #: 2735 Date Captured: 10/14/14

Color: Bay Captured: Palomino Buttes (OR)

Notes:
Tag#: 2735. This is a 2 year old bay gelding gathered from the Palomino Buttes HMA in OR in October 2014. Freezemark: 13022735

This horse is currently located at the Corral Facility in Hines, Oregon. For more information, contact Patti Wilson at email pwilson@blm.gov or Tara at tmartina@blm.gov.

Other pick up options: Ewing, IL (march 20); Montgomery, AL (March 27).
Adoption confirmation for this animal must be finalized no later than Noon Mountain February 12, 2015. After this date, all unclaimed animals will be available for in-person walk up adoption ONLY.

There were no bids placed on SAM during the Internet Adoption so he received another dangerous STRIKE